VENEZUELA DISSOLVES ITS CONGRESS, RAISING COUNTRY RISK TO THE HIGHEST LEVEL

The Supreme Court of Venezuela has dissolved the National Assembly, the last elected branch of government that contained any elements of the opposition. The Court ruled that it, and President Maduro, will now assume the duties of the Assembly, which the Secretary-General of the Organization of American States (OAS) has said is a step on the road to dictatorship.

With this step, Venezuela has clearly placed itself in the category of unsuitable, when it comes to Country Risk. Any financial exposure, from parties outside the country, now carried extreme levels of risk, and since recovery, through the government-controlled court system discriminates against foreign companies and nationals, any new financial intercourse should be avoided, lest total loss occur at maturity, as legal remedies in the event of default will not be available.

WILL PANAMA'S PRESIDENT PARDON MARTINELLI ASSOCIATES IN ODEBRECHT SCANDAL ?

Persistent rumors have been flying around Panama City this week, saying that Panamanian President Juan Carlos Varela intends to pardon a number of former President Ricardo Martinelli's close associates, ex-cabinet members, and possibly even family members, from any criminal charges filed against them, in the massive Norberto Odebrecht SA construction bribery scandal. Varela is often himself listed as a recipient of bribe money, so pardons of suspects in the Odebrecht case may be issued by the president for his own protection.

Martinelli's two grown sons, who were the alleged recipients of millions of dollars which was frozen in their Swiss banks accounts, may evade prosecution, if they are granted pardons. Whether the Panamanian people object to these actions is not known, but most are sick of the widespread corruption, which results in increased costs of everything, as bribe payments are added to the final cost of construction projects.

Is is doubtful that the former president will himself be pardoned;  he faces at least a dozen other criminal cases, pending against him in the capital. The US State Department has studiously ignored Panama's extradition request against Martinelli for months, leading many to believe that he is, or has been, a confidential informant for American law enforcement, or its intelligence services, like his predecessor, General Manuel Noriega.

LAWYER FOR MOSSACK FONSECA SAYS BRIBE MONEY IN MOSSACK ACCOUNTS WERE ADMINISTRATIVE FEES

In a statement that will certainly be regarded as shameful, the attorney represented the imprisoned law partners of Mossack and Fonseca has asserted that funds found in MF accounts that were bribe money in the "Cash Wash" scandal of Odebrecht, were "administrative fees." How millions of dollars, where were obviously bribe payments, meant to insure that the Brazilian constructions company obtained huge governmental contracts in Panama, are fees is an insult to the intelligence of  Panamanians.

The court continues to refuse to release Mossack, Fonseca, and MF partner Edison Teano, on bail, finding that they are flights risks, and pose a danger of destroying additional evidence, as they have done in the past. Money laundering charges are filed and pending, but the investigation is continuing.

REZA ZARRAB BRINGS IN THE BIG GUNS, FOR POSSIBLE PLEA NEGOTIATIONS

Correspondence from both sides, in the Reza Zarrab Iran sanctions evasion case, indicating that the Government believes two additional new attorneys, coming in to assist, may present still more Conflict of Interest issues, due to the fact that their firms have represented, or still represent, financial institutions the Government asserts are victims of Zarrab's illegal sale of Iranian oil for gold scheme. Wait until you hear who those two attorneys are.

First, the Government disclosed to the Court that Rudolph Giuliani, the former US Attorney, and ex-Mayor of the City of New York, and Michael Mulcasey, the Attorney General of the United States in the Bush Administration, and himself a former Federal judge, were representing Zarrab, and thus there were Conflict of Interest issues that the Court needed to adjudicate. These are two noteworthy additions to the defense team.

Then defense counsel, in a follow-up letter, denied any conflict, and indicated that the new counsel would not be participating in trial preparation, or trial itself. It also appears that they may not even be filing appearances for the defendant. So what are they coming in for ?

The answer can be found in the Government's second letter to the Court;

  "In this case, the Government has been expressly advised that Mr. Giuliani and Mr. Mulkasey have been retained by the defendant, and have been involved in, efforts to explore a potential disposition of the criminal charges in the matter."March 27, 2017 Letter from US Attorney's Office to the Court, at Page 2.

We recently wondered, in this blog, whether the lack of record activity in the case indicated a possible move to seek to settle the matter, through a plea negotiation; Apparently, this is now more than pure speculation on my part. A plea agreement generally involves cooperation with law enforcement, and may rise to the level of Substantial Assistance in the indictment of additional defendants, and/or the seizure of assets that are the proceeds of crime. Whether there will be many individuals charged is the question in the minds of most observers; we shall see whether it comes to pass.  One Turkish banker, linked to Zarrab's illegal operation, was arrested in New York this week. Did Zarrab supply information ? Was an indictment of the banker the sealed file posted on the court docket this week ?

Meanwhile, the Court has set another schedule of submissions, to determine if there truly is a Conflict of Interest, regarding these two new attorneys.

DOMINICA SEEKS TO LEGITIMIZE ITS ILLEGAL DIPLOMATIC PASSPORT PROGRAM

Readers of my articles will recall that I have repeatedly pointed out that Dominica's diplomatic passport program, which presents a clear and present danger of facilitating financial crime on a global scale, is not based upon any local laws or regulations. Last night, when I was a panelist on a talk program from the East Caribbean, discussing both CBI and diplomatic passport issues, a prominent Dominican developer, (Sam) when pressed by yours truly on the diplomatic passport program, brought out a newly-issued set of governmental guidelines, which he asserted now give the program a regulatory framework. I beg to differ, but I don't buy it.

Dominicans who have read and analyzed this 5-page document, which was reportedly drafted by a consultant, state that its content is on a elementary level, has no enforcement provisions, and is merely a set of good practices guidelines. In essence, it is a feeble attempt to legitimize an illegal program, which is in direct conflict with the requirements of the 1961 Vienna Convention on Diplomatic Relations, including:

(1) The use of non-Dominicans as "diplomats." This may only be done in extreme circumstances.
(2)  The failure to give these foreign diplomatic passport holders actual duties and missions.
(3) The failure of Dominica to accredit each "diplomat" to the country where he will be allegedly practicing diplomacy.
(4) The failure of these bogus diplomats to be presented & received at the country where they will be acting, and the acceptance of their credentials by the receiving country.

Sam, I also do not buy your argument, that Dominica is a poor country, which does not have the budget and resources to cover the globe with its diplomats, and therefore, it must rely upon foreign nationals to get out the word about Dominica, at their own expense. Dominica does not need a diplomatic mission in every distant and obscure country, and to argue otherwise betrays an alliance with powerful forces in Dominica that are only in the diplomatic passport issuance game for the money they can glean from it.

If Dominica cannot free itself of its illegal diplomatic passport program, then expect the bank compliance officers of the developed world to look very hard at any and all Dominican passports, presented at account opening, or for transactional work, as the word spreads of the misuse, by financial criminals, dodgy fraudsters, and the usual suspects, of passports from that country. If you haven't yet seen the rogues' gallery of Dominican diplomatic passport holders, known to have passports, read the article on the subject that came out a while back, in the Sun Dominica.

 Does Dominica really want to be named & shamed, like St Kitts was, for illegal passport fraud schemes, which is what play-for-pay passports are regarded as, by compliance, as well as immigration, officers ?

KEN RIJOCK DEMONSTRATES HIS HIGH-TECH SOLUTION TO THE CORRESPONDENT BANKING CRISIS

 If you have been reading my recent articles about the correspondent banking crisis, which has greatly affected banks in the Caribbean, and Latin America, and how I have asserted that Know Your Customer's Customers, or KYCC, is the only effective response to the situation, you are cordially invited to watch a live demonstration of the high-tech solution to the problem, in Miami, next week.

I will be lecturing on the subject, and actually demonstrating the program that solves that problem, next Wednesday, March 29, 2017, between 8:00AM and 11:00 AM, at the Intercontinental Hotel, in downtown Miami, at a special presentation;There is no charge to attend.

What if you could perform customer identification, Know Your Customer's Customers, & AML/CFT, in one integrated program ? Global Risk & Data Authority (GRADA) announces the FIRST online customer identification platform, to accelerate on-boarding, while simultaneously performing automated KYCC, for your correspondent banks abroad. 

The platform also incorporates a highly effective Second generation, cloud-based resource for AML/CFT, which bundles CIP, KYCC, and AML, on one multipurpose solution.

I invite you to attend my free lecture next week:

Location; Intercontinental Hotel
                100 Chopin Plaza
                Miami, Florida

Time: 8:00 AM to 11:00 AM


Schedule:
                   8:00   Service of Continental Breakfast for attendees.
                    
                   9:00   Kenneth Rijock discusses AML 2.0 and the correspondent banking crisis

                   9:30   Demonstration of the first KYCC Solution for banks and their correspondents.

NOTE: All attendees with receive a free autographed copy of my autobiography, The Laundry Man, which was published in the United Kingdom by Penguin. It is not available in the United States, and this is your only opportunity to acquire a copy from the author.

Who should attend: bank and MSB compliance officers, attorneys for financial institutions, compliance consultants, accountants, and all professionals who conduct due diligence investigations.

RSVP to:   events@grada.io or miamicompliance@gmail.com

For further information, visit www.grada.io  .

 

 

LANDMARK US GOVERNMENT REPORT ON OBIANG DOES NOT MENTION VLADIMIR KOKOREV AT ALL

In addition to our previous coverage of the illegal detention of the Russian-Spanish businessman, Vladimir Kokorev, his wife and son, in the Canary Islands, on bogus material witness charges, without any criminal case ever having being filed, against them, there is an investigative report, for an unimpeachable source, the United States Congress, that confirms that Mr. Kokorev had absolutely nothing to do with any money laundering activity, with Equatorial Guinea's President Obiang. I am wondering why nobody ever brought this fact up to the judges who are holding Kokorev, without legal cause or justification, in a remote location, far from the judiciary in Madrid, who need to put a stop to this human rights violation.

Back in 2010, the United States Senate Permanent Subcommittee on Investigations, released a 323-page report on  foreign corruption. In that report, the Subcommittee detailed financial transactions of a number of foreign officials, including the president of Equatorial Guinea, Teodoro Obiang. Nowhere in that report does the name of Vladimir Kokorev or of any other members of the Kokorev family, appear, which clearly confirms that he was not engaged in an criminal activity, on behalf of President Obiang. So why is Spain still holding him, under squalid and unhealthy conditions ?

The failure of the report to name him, for any purpose, or reason, means that investigators, from the United States Senate, which has almost unlimited resources, could find no evidence that Kokorev engaged in money laundering, which the Canary Islands prosecutors have alleged, thought they have never filed any criminal charges, nor is there any information indicating that criminal charges will be filed in the future.

The illegal detention of the Kokorev family, is merely the illegal effort, of the local judiciary, to seize property and assets of foreign nationals, but arresting them, and holding them for years, to steal their assets, after they leave Spain, after their belated release. These are serious human rights violations; the Kokorevs should be released forthwith, and the judges, who kept a sealed "secret" file on them, and interfered with his legal representation, permanently removed from the bench.

MMM PONZI SCHEME IS BACK, THIS TIME IN CANADA

A young lady who says her name is Alinka Karpova has, on her Facebook page, published a solicitation for a new version of the old "MMM" ponzi scheme, which you may recall started in Russia in the 1980s, and spread all over the investor world. Evewryone lost their shirts, but, like Colombia's DMG, it is back with new clothes on. MMM, now calling itself "Myanmar MMM," is advertising up to 100% per month returns !

Some things never change. Reports from Toronto say the new Ponzi scheme is already drawing in victims. I guess nobody is remembering to initiate due diligence on the name, for if they do, the whole sordid story is easy to find.

IS THERE A NEW INDICTMENT IN THE REZA ZARRAB CASE ?

Since the District Judge in the Reza Zarrab Iran sanctions evasion case, pending in New York City, denied the Government's motion to disqualify some of the defense counsel, for conflict of interest, filings in that case have been minimal. Outside of a request to authorize payment, for an affiliated attorney who has expended a couple of hours, which was granted by the Court, there have been no filings of pleadings, but a new one has received my attention.

A sealed filing of a document in the case occurred yesterday. Give the total lack of record activity of late, there are a number of interesting possibilities, regarding that filing, which is not electronic, but appears as a hard copy, and is placed in the court's vault for safekeeping. Only a very limited number of court staff have access to sealed documents.

What is in the document ? Here are a number of the most likely possibilities:

(1) A new sealed indictment has been issued. Grand Jury Indictments remain sealed, until the defendant is in custody, which means, if he or she is outside the United States, it will remain so, until arrest and/or detention for extradition. A number of individuals in Dominica, including government officials, agency staff, and professional advisors, could be named as well as targets located in the Middle East.

(2) A plea agreement may have been filed; it is possible that Zarrab have entered into a negotiated plea with the US Attorney's Office, and that agreement has been reduced to writing. Some Turkish media are claiming that this is now a real possibility, since the existing US Attorney has been terminated.

(3) National Security documents may have been filed; there is a chance that documents, regarding Iran, which affect the national security of the United States, or are classified for any reason, were filed.

(4) A new defendant/target has cooperated, and his Information is sealed to prevent others from fleeing to avid prosecution, to protect the cooperator's family, or to in some other way endanger law enforcement, or cooperating individuals overseas.

Whatever in in that sealed document, we shall continue to monitor all developments in this case, as they occur, as well as commentary upon the matter, from the Middle East and the Caribbean region.  

COMPUTERS AND PERSONAL ELECTRONICS TO BE BANNED FROM FLIGHTS ORIGINATING IN THE MIDDLE EAST

From Royal Jordanian Airlines notice

According to multiple reports, passengers on flights from several Middle Eastern countries, to the United States, with be prohibited from bringing on board laptop computers, and any other electronic gear, other than cellular telephones. This new rule is to go into effect in 96 hours, according to some reports that have not been confirmed. The prohibited items can be brought in checked baggage.

Additionally, There are rumors of new security alerts, believed to go into effect today.

WILL REZA ZARRAB PLEAD OUT, AND NAME OTHER CONSPIRATORS ?

Media in Turkey, where the Iranian-Turkish gold trader Reza Zarrab moved massive quantities of sanctioned Iranian oil, have expressed glee at the news of the firing of Preet Bharara, the United States Attorney for the Southern District of New York, the head prosecutor in the Zarrab case, for they believe that Bharara was intent upon taking the case to trial, which could result in a conviction, and a Draconian sentence for the defendant.

Turkish journalists now opine that, with a successor, appointed by the new American President, a plea agreement is a more likely outcome, which would hopefully result in a far shorter sentence than 75 years, which is the current estimated maximum that Zarrab could receive. He is reportedly held in high esteem by the Turkish public.

Unfortunately, these Middle Eastern media sources overlook the sad reality that a plea agreement would obligate Zarrab to identify other participants in Iran's billion dollar oil sanctions evasion program, and probably testify against them at their trials. while the other conspirators, such as Babak Zanjani, and Alireza Monfared, are likely to be indicted, based upon any cooperation rendered by Zarrab, there are others not known to the public, who might be named.

In addition to the other Iranian nationals who assisted Zarrab, Zanjani & Monfared, any serious prosecution might name West Indians who facilitated the Iran sanctions evasion operation, by granting Monfared a Dominican diplomatic passport, and assisting him in his global oil sales, and money laundering, scheme. Could Dominica's Prime Minister, Roosevelt Skerrit, and his two principal attorneys, be indicted for their roles in assisting Monfared to acquire a Dominican passport, and to move criminal proceeds ? Its is indeed possible.  If such individuals are indicted, that information will remain sealed, until they enter the jurisdiction of the United States, or are extradited, and we therefore may not know that information until arrests are actually made. Will Dominicans be brought to justice for their participation with Monfared in sanctions evasion money laundering ? We cannot say at this point, but we will be watching.

If Zarrab decides to cooperate, the first sign will be a change of plea hearing; after conviction, his sentence may get reduced, with no publicity or fanfare, a year or more after his very public sentencing. We will continue to monitor the case as it unfolds. 

ATTORNEY FOR MOSSACK AND FONSECA FILES HABEUS CORPUS, SEEKING THEIR RELEASE FROM CUSTODY

Abogada Macdonald

The attorney for Jurgen Mossack, Ramón Fonseca Mora, and Edison Teano, three senior partners of the disgraced law firm of Mossack & Fonseca, has reportedly filed for a Writ of Habeus Corpus, in a new attempt to obtain the pretrial release of her clients, whose alleged money laundering and tax evasion activities, on behalf of a multitude of clients, were brutally exposed in the Panama Papers. 

Guillermina Macdonald, a former prosecutor herself, who represents the incarcerated MF lawyers, will now have her clients brought before a judge, who will determine whether they are being illegally held. The Court previously ruled that they must be detained, upon these grounds:

(1) The three lawyers are a flight risk; they are wealthy, and face criminal charges which could subject them to long prison terms.
(2) The Court fears, correctly, that they may, if released, destroy evidence. Panamanian law enforcement has previously found, in an obscure apartment controlled by MF, huge amounts of shredded and discarded legal files.

It is doubtful that any court will allow their release on bond, given prior rulings, the evidence thus far, and the high profile nature of the Brazilian case, which is popularly known as Car Wash," by the Brazilian media. Of course, given the rampant corruption present in the Panamanian court system, and Fonseca's close ties to Panamanian President Varela, the MF lawyers may never be convicted.

Should they be extradited to Brazil, however, their conviction and incarceration is much more likely; the Government of Brazil has already taken down many powerful defendants, linked to the widespread bribery, by Norberto Odebrecht SA, and I am sure it will want some more trophies.

 

DOMINICAN "DIPLOMAT" WAS KIDNAPPED BY IRANIAN AGENTS, NOT PROPERLY EXTRADITED

Alireza Monfared and Dominica PM Roosevelt Skerrit

Alireza Monfared, the Iranian oil sanctions evader, whose Dominican diplomatic passport ignited a firestorm of controversy in that country, over the latest in a series of questionable issuance of diplomatic credentials to international financial criminals, was not, according to new information supplied by reliable sources, legally extradited from the Dominican Republic. The oil trader was actually kidnapped, and not by "INTERPOL agents," as previously reported in the media, but by Iranian intelligence agents.The two countries have no existing extradition treaty in force.

Monfared has been previously identified as an agent of Iranian intelligence, a fact that he did not disclose, when he filed an application for Dominican citizenship, pursuant to the Citizenship by Investment Program, before securing a second document, that illicit diplomatic passport, delivered to him, in Malaysia, by Prime Minister Roosevelt Skerrit, under circumstances that suggest corrupt activity.

Newly available sources have confirmed:

(1) Monfared escaped arrest, in Malaysia, by virtue of his Dominican Diplomatic passport.
(2) Iran again sought to take him into custody in Dominica, where he resided next but the Skerrit government protected him, and refused to hand him over; he brought a mistress, not his wife, with him, to Dominica.
(3)Dominica did facilitate his trip to the Dominican Republic, a popular location for wealthy Iranian expats.
(4) Extradition formalities were not followed in the Dom rep; he was forcibly taken, and transferred to Havana, where he was put on a nonstop flight to Moscow, bypassing the United States.
(5) the extent of the role of Israeli and American intelligence agents in the Dom Rep, in this case, remains murky; were they also seeking to kidnap Monfared ? Was that why he was repatriated, using the old "Cold War" transit route, which avoids US airspace and airports ?

When he arrived in Tehran, Monfared  reportedly asserted his status as a diplomat, but his claims were ignored by Iranian authorities, who promptly placed in a maximum security prison, but have not charged with criminal activity, in the $3bn theft of government oil profits. There has been no mention of Monfared, in government-controlled Iranian media, since he was taken into custody. His knowledge of classified information may preclude a public trial.  

LOCAL REMEDIES PROPOSED TO SOLVE CARIBBEAN CORRESPONDENT BANKING PROBLEM IGNORE THE PIVOTAL ISSUE

Several Caribbean commentators have weighed in on a possible fix to the urgent Caribbean correspondent banking situation. We present their theories here, in an effort to compare and contrast them to the only effective solution we can recommend, which is total KYCC*.

These concepts have been advanced in the financial media:

(1) To consolidate or merge the local financial institutions, in each country, into a sole entity, which will then field one large, seemingly effective, well funded, compliance department, which will handle Customer Identification Procedures, AM/CFT, Suspicious Activity reporting, training and all other issues, for all the what are then branches. It is thought that such a strong compliance unit will instill confidence on the part of the US banks, and allow retention of existing correspondent relationships.

This approach, which appears sound, does not really afford a New York bank either a better glimpse into the bank's customers, nor does it offer anything more than that which the individual compliance officers gave, when the banks were not merged. If anything, a master national compliance unit will be remote from the actual branches, and dependent solely upon material sent in, by New Accounts staff. It could also result in additional processing delays, which is not helpful when new accounts are opened, while CIP is in process, because money laundering on a one-shot basis could occur, while waiting for the unified compliance office to return results. 

There may also be business considerations, which would interfere with universal implementation. Local bank shareholders might fear a loss of control, loss of their brand, an inability to attract new customers to their now-anonymous "branch," and diminished profits at the end of each year, due to increased expenses, both in compliance, as well as administration. Will unprofitable or low-profit banks be dissolved ? It could result in administrative issues not foreseen by the proponents of this potential solution.

(2) To create a truly regional central bank, including all the nations, overseas territories and possessions in the Caribbean, using the eight-member ECCB as a model. This new central bank would process all transactions first, and raise the level of AML/CFT compliance to an acceptable plateau. In essence, transactions, and parties, would be subject to further examination at the central bank's facility.

I fear that this is even more remote than choice (1), because the central bank has no role in initial Customer Identification Procedure, at the bank sending funds through it, and unless it has an exceptional large, and efficient, staff, which can quickly conduct the enhanced due diligence investigations that it is bound to encounter, it will only result in major delays, which the banks' customers will find objectionable and unsatisfactory. Also, assuming that such a central bank's inexperienced compliance division will not be operating at peak efficiency for an extended period of time, US banks may find that its initial compliance failures painful, damaging, and exposing them to sanctions and penalties by US regulatory agencies.

I return, therefore, to my original solution, which is Know Your Customer's Customer, or KYCC. Caribbean banks must give onshore correspondents a total and complete window into their own clients' profiles an backgrounds, if they are to be true to a risk-based compliance program, that meets best banking practices. Anything short of that will not give American bankers the confidence that they need to retain all their Caribbean correspondents. Readers are invited to use the two available search boxes on this blog,  to access my previous articles on KYCC.
 ____________________________________________________________________________
 *If US banks add to that KYCC formula, an increase in the efficiency of their in-house KYC, with their own customers, and upgrade their AML/CFT abilities, they will reduce risk to an absolute minimum.

WHO IS PAYING FOR THE AMERICAN CRISIS MANAGEMENT FIRM HIRED BY DOMINICA ?

 If you read the fine print, in the contract between the Commonwealth of Dominica, and the American crisis management firm, Mercury Public Affairs LLC, you know that the company is charging a fee of $30,000 a month. That's a lot of money to pay, for spin doctors, and Dominica can least afford such a hefty payment, each month, especially for a firm with no track record in the Caribbean political environment.

So who is actually paying the fees ? Some observers and commentators are betting that it is actually coming from one of the forms that profits from sending clients to Dominica's Citizenship by Investment (CBP) program, or maybe by one who refers clients to the country's under-the-table diplomatic citizenship scheme, which allows dodgy foreign nationals to acquire a diplomatic passport, to use as they please in international travel, including to facilitate the commission of financial crimes, or providing material support to state sponsors of terrorism.

If one of those sleazy firms that sends clients to Dominica's CBP, or diplomatic passport, programs, is supporting an American damage control/crisis management firm, by paying its fees, we wonder what benefits it will expect the Government of Dominica to confer, in return.

WHERE IN AMERICA IS THE PRINCELING, BO GUA GUA ?

Bo Gua Gua, the son of a prominent (and utterly corrupt) former Chinese government official, who, together with his wife, will probably spend the rest of his life in custody, for poisoning a British businessman, is nowhere to be found. We are wondering where he is at present, somewhere in the United States, with probable access to millions in criminal bribery proceeds. What exactly is he doing in 2017 ?

You may remember that Bo, who received a top-drawer education, in both the UK and the US, was attending Columbia Law School, class of 2016. The problem is, he is NOT listed with his graduating class, on the Columbia website. Did he drop out of law school? Why did he fail to complete his studies in the normal three years (which is unusual for full-time law students), and why is there absolutely nothing about him since June 2016, in the global media ? Yes, I tried using the alias Bo used, during his student days, to conceal his true identity, but no luck with my research.

Yes, I know the US Government often coddles these "princelings," the children of senior Chinese Government officials, keeping their identities secret from their fellow students, less they be asked about their nations's Draconian anti-freedom actions, but where in the world is this young man, said to have access to his parents' dirty money, and is extremely arrogant, and rude to one and all ?

Some commentators says he drove some sort of bargain with Chinese authorities, resulting in their decision to leave him alone, but where is he banking all that illicit wealth ? We do not want it in financial institutions located in the United States. Perhaps his public relations firm will respond to this article, and disclose his current location, and activities.

PANAMA CLAMPS DOWN ON NON-RESIDENT FOREIGNERS

 
The Republic of Panama has begun strict enforcement of its "tourist" visa regulations. Until recently, foreign nationals did not need to obtain residency; they just lived in the country for the maximum six month permitted to tourists, and then exited the country, only to turn around and re-enter, being considered eligible for yet another six months. this fiction allowed foreign nationals to avoid the residency application process, and the white-collar criminal element living there, which could not pass the background check, ans was therefore free to engage in money laundering, or other financial crime. This abuse of the tourist visa will now come to an end.

This is not longer permitted; foreign nationals, residing pursuant to the tourist visa, now must remain outside of Panama for one month, to be allowed to return, as tourists. The old trick, skipping over to Costa Rica, and back, will no longer work.

Overstaying has serious consequences; "tourists" who stay past their required departure date are not allowed to exist the country, and are fined $2000 ; an expensive lesson about punctuality, I think. According to a notice, distributed by the US Embassy in Panama City, foreigners reentering Panama may be asked to prove that they are entering Panama as tourists, and not residing there.

The other problem is that tourists are not permitted to obtain Panamanian Driver's Licenses, and may only drive a motor vehicle in Panama for 90 days, with no exceptions. This rule obviously is intended to eliminate the ability of a "tourist" to secure full-time employment, or operate a business in Panama.

Whether the large number of Venezuelan money launderers, who regularly ply their dark trade in Panama City, and who reside in the capital for extended period of time, will be affected, is not known.

CARIBBEAN BANKS TAKING HEAT FROM ALL QUARTERS IN CORRESPONDENT BANKING SITUATION

 Indigenous financial institutions, located in the Caribbean region, continue to battle to retain their correspondent relationships in the developed world. In addition to the terminations that are inflicted upon them from the United States, banks in the countries of the European Union are also ending correspondent accounts, some of them being longtime relationships. This was recently noted in an article quoting staff at the East Caribbean Central Bank.

Other financial institutions have chosen to increase, even resorting to doubling, the costs of maintaining those correspondent relationships, in what may not be an attempt to recover increased compliance costs, but efforts to turn correspondents into mini profit centers. Caribbean banks, in general, can ill afford doubled transaction costs, nor can most of their clients.

Those few plucky US banks actively seeking to initiate new Caribbean partners are hard to find, and their active solicitation roles often mask basic needs; to possibly increase capital, develop new profitable markets, to offset prior losses, or to establish niche markets in a high-risk specialty. They may later experience fatal problems, or be sold off at a loss, stranding the correspondent banks who threw their lot in with them, not seeing the risks involved; They are to be avoided.

Therefore, with Caribbean banks coming to regard correspondent relationships as an endangered species, and unable to raise their compliance standards to a level which would provide total comfort for their US correspondents, the only acceptable solution is to present such an effective KYCC package which will completely satisfy any major American bank.

Caribbean banks that want to survive the de-risking phenomenon, and even expand their correspondents, must give them the same level of KYC that the US banks have with their own depositors. when KYCC in the correspondent equals the amount of KYC in the mainland bank, the problem is solved, permanently.

if you have missed our other articles on the subject of KYCC, email me at:
 miamicompliance @gmail.com  and I will send you the links to those articles.

EMBATTLED DOMINICA REFUSES TO BE TRANSPARENT ON DIPLOMATIC PASSPORT SCHEME, AND ENGAGES AMERICAN CRISIS MANAGEMENT FIRM TO SPIN THE TRUTH

The Prime Minister, and the Foreign Minister, of Dominica, continue to refuse to disclose the names & nationalities of the individuals who have purchased diplomatic passports, all outside of the normal method of qualifying, and appointing diplomats; they have also flat out refused to show precisely how much money they have paid for these extraordinary documents, which generally allow the holder to avoid both customs and immigration at national frontiers, and ports of entry. Considering that there is no provision for the issuance of diplomatic passports in the Citizenship by Investment Program, it appears to be illegal on its face, and all those involved in issuing those bogus passports deserve to be sacked; their arrogance should shock you, as they are supposed to be public servants, in a democracy, and not kleptocrats.

In lieu of full disclosure, the Government of Dominica has engaged, at substantial cost, an American "crisis management" consulting firm, known as Mercury Public Affairs LLC, at the rate of USD$30,000 per month. The contract term is for three months, but it can be extended, on a month-to-month basis, thereafter. The contract term began on February1, 2017.

We know about the contractual relationship. between Dominica & Mercury, not Because of any public announcement, as we can find none, but because Mercury was required, by US law, to register as a Foreign Agent, and file a copy of its contract with the Commonwealth of Dominica.

The specified tasks that Mercury intends to take on, according to the agreement, include responding to negative news. We have seen no evidence of any spin doctor activity, and therefore ask the question: why spend this kind of money, to confuse Dominicans about the truth of the current situation, regarding the diplomatic passport scandal, when the country is still reeling from the utter damage done to its agriculture, from the last hurricane ? Government assets should go towards rebuilding, and fostering economic development, not engaging spin doctors, to hide the truth.

Those illegal diplomatic passports pose a serious danger to the global banking community, for they allow the holder to masquerade as a respected, legitimate diplomat, who could use that cover to commit financial crime, terrorist financing, and yes, billion dollar fraud. That bogus program should be terminated, forthwith.

PONZI SCHEMER'S ATTORNEY SAYS HE WILL BE DEPORTED TO COLOMBIA THIS YEAR

A Colombian attorney, representing the convicted Pyramid/Ponzi schemer, says that David Eduardo Helmut Murcia Guzmán, the Colombia Bernie Madoff, who stole millions from Colombians, and was sentenced to prison in the US, will be deported home later this year, after his American prison sentence is completed. Murcia was given a 20-year sentence in Colombia, where he only served a small portion, before being transferred to the US, meaning that he owes Colombia a lot of prison time,

The announcement, of his future deportation to his native Colombia, conflicts, however, with repeated rumors that Murcia was placed in WitSec, the Federal witness protection program, and has already been released. Some unverified reports have him outside the United States, and seeking to recover money misappropriated from him, when he was summarily arrested in Panama, and deported to Colombia, against Panamanian criminal figures who stole from him.

Murcia, who was incarcerated in a local jail, rather than the Federal prison system, is believed to have been cooperating with American law enforcement for years. The millions of dollars he stole, in his DMG Ponzi scheme, grew to billions, which was sent to Panama, and much was reportedly FARC drug profits that he was allegedly laundering, by purchasing real estate units in Panama, financing building construction, and through other means of placement of the proceeds of crime.

So, which version is correct ? Is Murcia a free man, hidden somewhere in the America, in WitSec, or has he been serving out his sentence in a small jail in the northeast US ? We cannot say, but eight months from now, when his sentence expires, we will learn the truth. 

THE CARIBBEAN CORRESPONDENT BANKING CRISIS: IT IS NOT ABOUT PROFITABILITY

Some of the commentary surrounding the origins of the present situation, regarding the large number of correspondent banking relationships terminated by American financial institutions, has centered upon the large number of Caribbean banks that have reportedly lost their US corespondents, and two of the major reasons cited, as a park of the so-called "de-risking" process, are the lack of profitability for onshore banks, and increasing compliance costs, regarding their correspondents.

While all financial institutions focus upon earning a profits for their shareholders, the primary reason, if the truth be known, for terminating correspondents in the Caribbean region has to do with the risk-based compliance program American banks must follow. American banks have, for decades, worked with their Caribbean correspondents, in many cases, where the amount of business between them is relatively small, but the arrangement serves, not only the Caribbean banks' customers, but the American institutions' as well. It is all about risk management; the profitability reason merely seeks to soften the blow of loss of correspondent for business reasons, but it is not accurate.

The  risk-based approach to compliance demands that, where risk levels cannot be reduced to acceptable levels, the relationship becomes a liability, and is to be terminated. For that reason, the Caribbean banks must institute their best, and only, response to the challenges, and that is to implement a KYCC program, which will then restore confidence, on the part of the North American bank, as it will reduce risk to not only a manageable level, but to all intents and purposes, eliminate it, when it comes to the caribbean bank's customers.

Readers who have not read all my recent content on the subject of KYCC are invited to access it here.

DID NIGERIAN DIPLOMATIC PASSPORT HOLDER DEPOSIT HER FLIGHT CAPITAL IN DOMINICAN BANKS ?

Investigators probing the corruption case of former Nigerian Minister of Petroleum Resources, Diezani Allison-Madueke, who allegedly stole billions of dollars from the Nigerian National Petroleum Corporation, NNPC, have been wondering whether she secreted any of her misappropriated wealth in Dominica. While Nigerian government officials seized over $150m, in dollars, and Nigerian currency, they believe that Allison-Madueke was able to spirit billions overseas. $20bn is the estimated amount that she allegedly misappropriated, and she reportedly personally retained $6bn.

The then-fugitive former oil minister, who obtained a Dominican diplomatic passport, reportedly facilitated by Prime Minister Roosevelt Skerrit, had the passport among her possessions, when she was arrested in the United Kingdom, for money laundering. Her trial is scheduled for June. Whether she used the passport in international travel, to avoid identification as a Nigerian PEP, is not known.

Sources in the UK advise that Allison-Medueke was introduced to Skerrit by Baroness Scotland, a close friend of Skerrit, and that the former oil minister asked Skerrit where she could hide her "flight capital." For that reason, the question remains: did Allison-Madueke deposit stolen millions in banks in Dominica, or otherwise "invest" some of her assets in that country ?    

EIGHT OTHER PROMINENT PANAMA LAW FIRMS IMPLICATED IN ODEBRECHT BRIBERY SCANDAL

Eight other major Panama City law firms have been named, for their role in the Odebrecht/Lava Jato (CarWash) bribery scandal. Apparently, these firms all formed corporations linked to the payment of bribes, by Norberto Odebrecht SA, the Brazilian construction company, to obtain lucrative government contracts in Panama. Some of the corporations facilitated the hidden payments, while others were involved in laundering the criminal proceeds.

While the names of these law firms, some of whom are among the oldest and most prominent in the Republic of Panama, may give foreign investors pause, when choosing whom to engage in legal representation, it is not known which lawyers knew the companies were obtained for an illicit purpose, and which were kept in the dark, by their clients, who were high-level government officials in Panama. Nevertheless, the principal law firms in Panama may now find themselves under a cloud, due to the scope of the $59m bribery scandal, which has reached into the private dealings of both present, and former, government officers, including some at the highest level.

WHY DO SOME REAL ESTATE WEBSITES LIST THE PRIME MINISTER'S $2m NYC PURCHASE AT $7.7m ?

If you are one of those readers who has been Googling the information, regarding the New York City luxury second home, of the beleaguered Dominican Prime Minister, Roosevelt Skerrit, you may have stumbled upon something curious. Just how much did that condominium sell for, when the Prime Minister, who shows only nominal income, as national leader of a developing country, purchased it ?

Here's the mystery: was the condominium, where the PM's wife and children presently reside, but where the PM himself does not visit, purchased for $2.2m, or for $7.7m ? We cannot say, but the real estate websites show both sales prices. We hope that some of our readers can shed some light upon this dilemma. We would, of course, like to know where the purchase money came from.

MARTINELLI'S ATTORNEY NAMES INDIVIDUALS AND ENTITIES HE ALLEGES LAUNDERED ODEBRECHT BRIBES

Prominent Panama City Attorney Sydney Sitton, who is part of the defense team representing the fugitive former president of Panama, Ricardo Martinelli, has, in a filing with the government, named individuals and corporate entities that he alleges laundered bribe money, paid by Norberto Odebrecht SA, the Brazilian construction giant that may have paid as much as $59m, to Panamanian government officials, to obtain construction contracts in the Republic.

While you are cautioned that there is no independent confirmation that any of these named parties was involved in money laundering, risk-based compliance policies do require that, when such allegations are publicly made, you inquire, to ascertain whether you are banking any of these individuals or corporate entities. The list can be found here.
   

LATIN AMERICAN BANKERS STILL SEARCHING FOR CORRESPONDENT BANKING SOLUTION

I hear, from those who attended this week's conference of the Florida International Bankers Association (FIBA), that the sessions on Correspondent Banking failed to deliver a real solution on the issues of how to sustain, and expand, your correspondent banking relationships, in this era of extensive "de-risking, " by most major North American banks. Not only are there effective solutions available, which could serve as a guarantee that your correspondent accounts will be maintained, indefinitely, should you adopt them, I have detailed how they may be accessed, in previous articles on this blog.

Readers who have not seen my earlier articles on how to remove correspondent banking termination fears, please go to my article, entitled:

Here is the Solution to your KYCC/Correspondent Banking Conundrum

WILL REMOVAL OF US ATTORNEY IN NEW YORK MEAN MORE INDICTMENTS IN THE REZA ZARRAB IRAN SANCTIONS EVASION CASE ?

Ex-USA Bharara, and PM Skerrit

The newly-installed Attorney General of the United States, Jeff Sessions, has removed the sitting US Attorney for the Southern District of New York, Preet Bharara. It is Bharara who has been prosecuting the $400m Iran sanctions evasion case against the gold & oil trader, Reza Zarrab. Will a new prosecutor mean more indictments in this case ?

I make this point because the administration of President Donald Trump appears to be significantly more antagonistic to the regime in Iran than his predecessor, and you can expect the next US Attorney in Manhattan to share that position. While we do not know whether there are sealed indictments pending, in the Zarrab case, against absent or fugitive defendants, in the Middle East or elsewhere, such as Babak Zanjani, now facing the death penalty, or Arireza Monfared, the Zanjani partner extradited to Iran, whose possession of a Dominican diplomatic passport ignited a firestorm of controversy over the legitimacy, and possible corruption, surrounding his acquisition of that document, there may now be additional prominent defendants named, by Bharara's successor, who will want to demonstrate his resolve in prosecuting Iran sanctions violations.

Is the Prime Minister trying to dance away from an indictment ?

One possible co-conspirator who may have ready been charge, or who could now be added, is the Prime Minister of Dominica, Roosevelt Skerrit, whose close relationship with Alireza Monfared, now facing prosecution in Iran on corruption charges, has rejected widespread calls for his resignation, or removal from office. Questions to ponder about PM Skerrit:

(1) Since Monfared's arrests and extradition, the Prime Minister has refrained from travel into, or through, the United States, even through his wife, and child, have apparently permanently relocated to his $2m condominium in New York City. Does he fear a sealed indictment may be waiting for him in Miami, at Customs and Border Protection ? He may be staying out of America upon advice of his counsel that the risk of possible arrest, and pretrial detention, is too high to ignore, for  what would be solely a social visit.

(2) Has Skerrit's US visa been revoked ? Pursuant to Presidential  Proclamation 7750, of January 12, 2004, foreign officials involved in corruption, will have their US visa revoked, and barred from entry. This happened with the then-Prime Minister of St Kitts & Nevis, during their disgraced Citizenship by Investment scandal, and who has never had his visa restored since, even after he left office. Whether Skerrit has also had his visa revoked cannot be determined, as US privacy regulations do not allow that information to be publicly disclosed, but it may explain his strange failure to visit his family.

(3) Is there any truth to the story, roiling around Dominica this week, that the Internal Revenue Service (IRS) served some sort of warrant upon Skeritt's wife, at their secluded New York City luxury condominium ? Remember, they own that unit through a Delaware corporation, which generally is an attempt to hide the identity of the beneficial owner. If there are money laundering issues, arising out of the Source of Funds used for the purchase of that real estate, other possible charges could be filed.

We await the naming of USA Bharara's successor, and wonder aloud whether that individual will widen the scope of the case, and whether it will name additional defendants from the Caribbean, be they senior government officials, Citizenship by Investment officers, or even local bankers or attorneys.

Monfared and Skerrit

PANAMA'S ATTORNEY GENERAL PLACED UNDER INVESTIGATION FOR HER ODEBRECHT INVESTIGATION

Powerful forces in the Republic of Panama, smarting due to the exposure of several of their own to major bribe charges, in the Odebrecht case, have resorted to the usual Panamanian response to charges, what we call in North America "shoot the messenger." Kenia Porcell, the Attorney General of Panama, has been placed under investigation, due to allegations of Abuse of Power. A former deputy of Porcell has been assigned the judicial investigation.

Whether this investigation, obviously initiated for purely political reasons, and not for breach of the law, disrupts, or even kills, the Odebrecht $59m corruption case, cannot be estimated, but it will, at the very least, delay matters somewhat. Ex-president Ricardo Martinelli, and/or Panama's Syrian organized crime syndicate, are the probable actors in requesting the investigation.

DOMINICA'S FOREIGN MINISTER ON WHY SHE WILL NOT RELEASE THE NAMES OF ITS DIPLOMATIC PASSPORT PURCHASERS

For public review, and after Antigua & Barbuda has agreed to release the names of all its diplomatic passport holders, it is important to analyze the reasoning of the Foreign Minister of Dominica, Senator Francine Baron, when she was asked, in open session of Parliament, to disclose the names of all persons, who are not members of Parliament, who have diplomatic passports of the Commonwealth of Dominica.

The minister's response, on the record:

"The government has never, as a rule, publicized sensitive details, outside of the corresponding countries to which persons are engaged. Effective foreign policy is never practised in the media or the public domain. While the government could have no diplomatic appointment and postings established, it remains opposed to the idea of divulging information, on all appointees, in a forum that is essentially public in nature, and which the entire world has access."

What the minister is saying, in plain English, is that persons who hold Dominican diplomatic passports, irrespective of the fact that they have no specific duties assigned to them, are not posted to any specific country or region, and have no mission or task to perform or fulfill, will not be publicly identified. Individuals who are sold diplomatic passports have no such bona fide duties or responsibilities whatsoever, but this seems to have escaped the honorable minister.

Let's consider that the 1961 Vienna Convention on Diplomatic Relations  requires:

1. All diplomats must be accredited to the receiving country.
2. All diplomats must be, pursuant to protocol, formally presented, received and approved by the receiving country. That means presenting credentials,  together with a written request, from the sending country, to regard the holder as its true representative.
3. Diplomats are to be of Dominican nationality, except under the appropriate, but rare, circumstances, and if they are foreign nationals of the receiving country, they must be approved by the receiving country.

What we have here are foreign nationals, who purchase Dominican diplomatic passports, but are never accredited to their home country, nor ever formally presented there, nor ever are recipients of written waivers, which authorize them to act as diplomats, for any purpose.

In truth and in fact, the vast majority of foreign nationals who are sold diplomatic passports, are not legitimate diplomats, as their "appointments," are VOID as a matter of law, not voidable, as they fail to satisfy the requirements of the Vienna Convention ab initio. I would certainly like to see any opinion of counsel, which the Government of Dominica, relied upon, before it started issuing these bogus passports, which are obviously no more than expensive toys, but have no legal weight.

Somebody, somewhere, acting as legal representative of the Commonwealth of Dominica, committed legal malpractice, by approving the sale of these pay-to-play passports, without considering, and implementing, the requirements of the Vienna Convention. The government refuses, without just cause, to name its so-called "diplomats," who do not have bona fide credentials in the first place, and its leaders think that they can flaunt the law so brazenly ? These spurious, invalid passports are a bad joke, played upon the people of Dominica, and represent a clear and present danger to the rest of the free world.

PHOTOGRAPHS SHOW MOSSACK FONSECA TOOK ITS SIGNS DOWN

Picture taken today.

This is the sign that has been removed.

Another picture of the now-removed sign.

DID MOSSACK FONSECA CLOSE UP, OR JUST GO UNDERGROUND ?

An eyewitness, visiting the building to see another tenant, has reported that all the exterior signage of the law firm Mossack and Fonseca has been taken down, as well as the interior sign that directs visitors to their suite. While this may actually mean that the firm, named & shamed by the release of the Panama Papers, is closing up, it may also mean that it is just going underground, in its dodgy operations.

We have previously exposed nonpublic branches, of major international banks, located in Panama City, where there is no indication of the name of the suite tenant. This is an intentional means of keeping a low profile, away from public view, a sort of private, private bank. Is  Mossack Fonseca merely lowering their profile, due to the mass negative publicity it has received, and the arrest of its senior partners ? 

SHAKY CARIBBEAN GOVERNMENTS. FEARFUL OF OPPOSITION, TASK HACKERS TO DISRUPT FREEDOM OF THOUGHT

If you have been reading this blog since it first reported that the Prime Minister of Dominica is under investigation, in connection with Iranian oil sanctions evasion cases, you may remember that we warned you that the Skerrit Government had engaged professionals skilled in electronic surveillance, and that your private telephone calls, and emails should not be considered secure at this time.

Now, we have yet another disturbing item of news, regarding an activity that one might expect occurring, more likely, in a country where dictators terrorize their subjects, and not a democracy. We are talking about the current use of hackers, reportedly hired by government officials in Dominica and St Lucia, and other East Caribbean nations, to disrupt, damage, hack, and destroy, Internet postings by members of Opposition parties. 

While we are aware of the identities of the "professionals" hired to wreak havoc upon Opposition websites, Commentary, and articles critical of the government and party in power, we have chosen to limit the release of that information, and photographs, only to victims of these hackers, to allow them to take remedial action, based upon information that may assist them..

Lawyers for certain governmental leaders have been specifically named, as having paid these despicable individuals to disrupt freedom of the press, and freedom of information, implicating those attorneys as the sponsors of illegal acts, but you certainly know who those lawyers are, they are the apologists for their regime clients who themselves pollute the websites with their spin on the truth, what are called "alternative facts" lately.

Therefore, if the website, blog, or postings of an Opposition figure disappear from the Web, you can be sure that it was no accident, but a deliberate attack on freedom.  

KOKOREV STILL BEING DETAINED, ALTHOUGH POLICE CERTIFY THAT THERE IS NO CASE PENDING

After eighteen long months, the Russian businessman, Vladimir Kokorev, and his wife and son, remain in illegal detention in the Canary Islands, notwithstanding that the Spanish Police have certified that they are not now, now have they ever, been under investigation, on alleged money laundering charges, there. The issuance of a certificate of good conduct, which was issued after an investigation of all the country's judicial districts, is yet another confirmation that their detention, supposedly as material witnesses, is contrary to Spanish law, and supports Kokorev's counsels' assertion that they are being held for purely political reasons.

Many legal observers have concluded that the Kokorev family are victims of human rights violations, due to the fact that powerful economic interests in Spain reportedly want them to give false testimony, in a criminal matter, against the president of Equatorial Guinea, with the object of driving him from office. Oil was discovered in EG, after it became independent from Spain, but American oil companies have been participating in the country's lucrative oil industry. Certain Spanish companies have reportedly sought to remove Obiang from office, with the object of inserting a cooperating expat in his place, and securing the oil business for themselves.

A member of the judiciary, in the Canary Islands, has classified the case where Kokorev is the purported material witness, so no information can be obtained by counsel, or the media, though no legal grounds can be found for this decision, which appears to deny Kokorev's attorneys access to sufficient information, as is necessary, to obtain his release from custody, on civil and human rights violations.

ALLEN STANFORD'S ACCOUNTANT SEEKS TO EVADE HIS 20-YEAR SENTENCE

Gilbert Lopez, the former chief accounting officer at the Stanford Financial Group, appears to still be seeking to evade the 20-year sentence that a District Court Judge handed down to him, for structuring sham transactions, and preparing bogus annual reports. Having lost at trial, on appeal to the Fifth Circuit, and having his cert petition denied by the US Supreme Court, he has exhausted all his appellate rights, but he has made one more filing, this one Pro Se.

Mr. Lopez now has the temerity, in a Section 2255 Petition, to claim that his trial attorney was guilty of ineffective assistance of counsel, for allowing him to go to trial, instead of permitting him to decline a 7-year plea agreement. Lopez claims that his attorney did not advise him of the possible consequences of rejecting the plea, of the strength of the Government's case, and of the fact that, due to the amount of money involved in the Ponzi scheme, his Guidelines sentence was life in prison.

Personally, I cannot believe that his counsel did not recommend that he accept the plea; I would venture a guess that Lopez' arrogance made him reject his own guilt, and, believing that he would prevail at trial, decided to take his chances at trial. This is what happens when you make a wrong tactical decision, and do not rely upon your attorney's expert advice. Remember, criminal defense attorneys are usually good judges of the weight of the prosecution's case, and their counsel should be followed.

Let justice prevail; the vast majority of these 2255 cases fail, because the defendant's failed to assert their defenses on appeal, and there is no legal excuse for this procedural error. Lopez cannot go to trial, and after losing, and losing on appeal, then come in and say his lawyer was ineffective, and ask for the 7-year sentence he initially, and unwisely, rejected.

GENERAL NORIEGA IN CRITICAL CONDITION AFTER BRAIN SURGERY

General Manuel Noriega, the former dictator of Panama, is in a drug-induced coma, in a hospital in Panama City, after suffering post-brain surgery bleeding. Noriega, who served prison time in the US for drug trafficking & money Laundering, and additional time in France, also for money laundering, has been serving a 20-year sentence in Panama, for multiple homicides. He had been released from prison, to undergo surgery for a benign brain tumor.

Noriega's attorney says he client is not longer bleeding in his brain, but will continue to be kept in a coma for the next five days, as a precaution.

MOSSACK FONSECA, STILL OPERATING, SAYS 250 EMPLOYEES HAVE BEEN TERMINATED

Mossack and Fonseca

The Panama City law firm of Mossack and Fonseca, its lead partners in custody, and its money laundering, tax evasion and corruption assisting operations exposed to the world in the Panama Papers, has announced that it has let go a total of 250 of its employees and staff members. Originally listed at 500 on staff, it is not known how many remain, as there have been a large number of resignations, especially by the attorneys working there. Former Mossack lawyers, who may have taken dodgy MF clients with them when they left the firm, are known to be under investigation.

The question remains: why is this firm still operating ? Do not Panamanian authorities have sufficient evidence to close it down permanently ? The possible reasons:

(1) Name partner Ramón Fonseca Mora was an adviser to Panama's President Varela, and he may have first-hand knowledge of corruption at the highest level. Is the delay in filing major criminal charges, due, in part, to Mora's ability to severely embarrass the present government ?

(2) There is, in essence, no disciplinary system in place in Panama for attorneys, and there may be no appropriate method for closing down a law firm, even if its partners are convicted of crimes. Lawyers have been known, in Panama, to return to the practice of law, after serving a prison term, with no interference from any regulatory authority. While you may find this absurd, it is completely normal in Panama.

Panama insiders advise that the MF employees are only "on leave" from their jobs, and they have been told they will be recalled. Given Sr. Fonseca's influence with the government, many in Panama are pessimistic, and believe that the MF partners will be acquitted of all charges, if they are even indicted, due to the rampant corruption in the country's court system.

Needless to say, the longer that Mossack Fonseca is allowed to form opaque corporations and trusts, in Panama, the BVI, Belize, and elsewhere, the country will continue to have a very visible black eye, visible to the global financial community. This means that new business, especially from foreign sources, will continue to decline, which will affect the Panamanian economy in a negative way, and affect Country Risk assessments accordingly.

WAS THE PRIME MINISTER ENGAGING IN BULK CASH SMUGGLING ?

Roosevelt Skerrit, the Prime Minister of the Commonwealth of Dominica, has recently taken two quick trips to the Dutch/French Island of St. Maarten, with first, a senior banker from Dominica AID Bank, and second, the manager of the country's Citizenship by Investment (CBI) program. Individuals who were on the aircraft reported that the travelers left their suitcases behind in St. Maarten.

Were they engaged in bulk cash smuggling of cash received in the opaque diplomatic passport program ? we cannot say, but all the evidence points to such a conclusion. Dominican banks reportedly have refused to accept even CBI funds, unless the actual due diligence report on the applicants is also furnished with the funds. Some reports from Dominica say that clients have been contacted, to come into the banks and withdraw the funds, in full. Other sources assert that some new payments were made in cash, and has been stored by the Skerrit government, while an acceptable depository is found, outside of Dominica.

North American regulators as well as bank compliance officers, are not going to look favorably on this information, especially since no legitimate governmental reason has been advanced for these two trips to a European overseas territory, and the manner in which the trips were undertaken lend themselves to the assumption that they were for private reasons. International travelers know that St. Maarten, a duty-free jurisdiction, does not inspect arriving travelers, or their bags & baggage, and there are a number of local, as well as international, banks, located there.

The arrest of five foreign nationals, from different jurisdictions, who all held Dominican diplomatic passports, but had no diplomatic postings, nor assignments, nor responsibilities to the government, has resulted in a national scandal over the diplomatic passport program, and a demand for the names of all participants, an an accounting of all funds received. An estimated $50m is unaccounted for, and whether some of these funds were in those now missing suitcases is a question that deserves an answer from the Government of Dominica.